Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 64.033, Department of Veteran Affairs, VA Supportive Services for Veteran Families Program Federal Award Identification Number and Year: 21-MI-221, 22-MI-221, 20-MI-221-SS, 20-MI-221-LT, 20-MI-221 Pass-through Entity – N/A Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 2 CFR 200.332 all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;(x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted.Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.569, Department of Health and Human Services, Community Services Block Grant Federal Award Identification Number and Year: E20230009-001, E20230816-01/E20242466-10, E20234409-002, E20234742-00 Pass-through Entity – Michigan Department of Human Services Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 2 CFR 200.332 all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.569, Department of Health and Human Services, Community Services Block Grant Federal Award Identification Number and Year: E20230009-001, E20230816-01/E20242466-10, E20234409-002, E20234742-00 Pass-through Entity – Michigan Department of Human Services Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 2 CFR 200.332 all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.569, Department of Health and Human Services, Community Services Block Grant Federal Award Identification Number and Year: E20230009-001, E20230816-01/E20242466-10, E20234409-002, E20234742-00 Pass-through Entity – Michigan Department of Human Services Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 2 CFR 200.332 all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.569, Department of Health and Human Services, Community Services Block Grant Federal Award Identification Number and Year: E20230009-001, E20230816-01/E20242466-10, E20234409-002, E20234742-00 Pass-through Entity – Michigan Department of Human Services Finding Type – Significant deficiency in internal control over compliance Repeat Finding – No Criteria – Per 2 CFR 200.332 all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) Condition – During our test work, we noted one instance where the subaward was not clearly identified to the subrecipient as a subaward and did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, was included in the grant agreement of its subrecipient. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted. Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients. View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2301KSOASS ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2301KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2023, the subrecipient received $180,658 ($31,619 - ALN 93.044, $149,039- ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2022-008 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.
U.S. Department of Health and Human Services, passed through Kansas Department of Aging Aging Cluster - ALN 93.044 - Special Programs for the Aging_Title III, Part B_Grants for Supportive Services and Senior Centers - 2301KSOASS ALN 93.045 - Special Programs for the Aging _Title III, Part C_Nutrition Services - 2301KSOAHD Criteria or Specific Requirement: Subrecipient Monitoring and Material Weakness Per 2 CFR 200.332, a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and terms and conditions of the subaward as well as monitor the activities of the subrecipient which include reviewing financial and performance reports, obtaining and reviewing subrecipient single audit reports, etc. Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: No risk assessment or ongoing formal monitoring of the subrecipient was performed. Questioned Costs: None noted. Context: There is only one subrecipient associated with this program. During 2023, the subrecipient received $180,658 ($31,619 - ALN 93.044, $149,039- ALN 93.045) from the Unified Government. The subrecipient for this program is a long-time subrecipient that is familiar with federal compliance requirements, but the risk assessment was not done in writing. Additionally, ongoing monitoring including reviewing for single audit filings were not completed. Identification of Prior Year Finding: 2022-008 Effect: Federal funds could be improperly utilized by a subrecipient which does not have an adequate understanding of the requirements or tools to support the program. Cause: The Unified Government has a long-time relationship with this subrecipient and did not formalize the risk assessment process. Further, formalized processes for monitoring subrecipients were not operating effectively. Recommendation: We recommend that the Unified Government develop procedures to perform a risk assessment on all potential subrecipients before entering into an agreement to provide federal funds to that entity and revisit annually thereafter. Additionally, formal policies and procedures should be put in place over the various levels of monitoring that may occur as a result of the risk assessment and should also include a trigger to ensure single audit reports of subrecipients are reviewed. View of Responsible Official and Planned Corrective Actions: The reason for recurrence is the finding was communicated late in the prior year and due to transition and turnover within the department's staff. Aging department is now completing these assessments annually.
Finding 2023-006 – Subrecipient Monitoring US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Cause: There were no procedures in place to document the City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the City should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable. Questioned Costs: Unknown View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-006 – Subrecipient Monitoring US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Cause: There were no procedures in place to document the City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the City should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable. Questioned Costs: Unknown View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-006 – Subrecipient Monitoring US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Cause: There were no procedures in place to document the City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the City should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable. Questioned Costs: Unknown View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-006 – Subrecipient Monitoring US Department of the Treasury – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (ARPA) (ALN 21.027) Condition: The City did not have a documented risk assessment process for evaluating subrecipient’s risk of non-compliance. Additionally, as part of the monitoring process, the City did not have controls in place to obtain and review the annual audit report of the subrecipient in a timely manner with documentation of such review. Criteria: The 2 CFR section 200.332(b) requires pass-through entities to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR section 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients. Cause: There were no procedures in place to document the City’s assessment of risk for the subrecipient. In addition, the City does not have procedures in place to adequately review the subrecipient’s audit received. Effect: The deficiencies in subrecipient monitoring could result in the City not identifying unallowable expenses being incurred by the City’s subrecipient. Repeat Finding: This is not a repeat finding. Recommendation: We recommend implementation of procedures to formally document and complete a risk assessment of subrecipients. Based on the risk assessment performed, the City should develop monitoring procedures to address the risks noted, which should include a documented review of subrecipient audits and deficiencies be followed up on, if applicable. Questioned Costs: Unknown View of Responsible Official: The City agrees. See the corrective action plan.
Finding 2023-004 – Subrecipient Monitoring Program Name: U.S. Department of Commerce Economic Development Cluster, ALN 11.307 Criteria of Specific Requirement: Pass-through entities are required to evaluate subrecipient risks of noncompliance as part of their subrecipient monitoring procedures. In addition, 2 CFR 200.332(d) indicates as part of the monitoring process, the pass-through entity should ensure subrecipients are notified of their requirement to receive an audit and take follow-up action on audit deficiencies, which would be identified as part of the review of the annual audit reports of subrecipients and 2 CFR section 200.332(a) required pass-through entities to notify the subrecipient at the time of the subaward of the subaward ALN and amount that was paid during the year. Condition: The Organization did not comply with subrecipient monitoring requirements around risk assessment monitoring, audit requirement language, including federal assistance listing number, within their contract, and review of subrecipient single audit compliance. Questioned Costs: Unknown Cause: The Organization does not have formal subrecipient monitoring policies and procedures in place to document the assessment of risk for subrecipients. In addition, the Organization does not have procedures in place to adequately review the subrecipient audits received, ensure that audit requirement language is included in each contract, or notify the subrecipient of the subaward ALN and amount that was paid during the year. Effect: The Organization was not in compliance with subrecipient monitoring requirements. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement procedures to ensure subrecipient monitoring includes proper risk assessment and monitoring of single audit compliance. Views of Responsible Officials and Planned Corrective Actions: Management agrees; see separate corrective action plan.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Finding 2023-003: Subrecipient Monitoring – Review of Audit Reports Information on the Federal Programs: Assistance Listing 98.001 USAID Foreign Assistance for Programs Overseas Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.332 discuss requirements for pass-through entities. Among these requirements are that passthrough entities must verify that a subrecipient is audited as required by 2 CFR 200 Subpart F. Condition: We noted an instance in which there was no evidence of Action Against Hunger’s review of a subrecipient’s audit report. Cause: Administrative oversight. Effect or Potential Effect: Noncompliance with subaward monitoring requirements may lead to withholding of future payments, award suspension or termination, and ineligibility for future awards. Questioned Costs: None.Context: Our sample consisted of three subawards. We noted the condition for one of the three subawards tested. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that management implement a standardized process whereby all sub-awardees are required to submit their annual audit reports to Action Against Hunger – USA for review, or confirm that they were not subject to an audit under 2 CFR 200 Subpart F.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331. Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries. Questioned costs: None. Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award. Cause: Lack of adequate knowledge about subrecipient monitoring requirements. Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight. Repeat Finding: No. Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b). Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331. Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries. Questioned costs: None. Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award. Cause: Lack of adequate knowledge about subrecipient monitoring requirements. Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight. Repeat Finding: No. Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b). Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331. Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries. Questioned costs: None. Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award. Cause: Lack of adequate knowledge about subrecipient monitoring requirements. Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight. Repeat Finding: No. Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b). Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331. Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries. Questioned costs: None. Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award. Cause: Lack of adequate knowledge about subrecipient monitoring requirements. Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight. Repeat Finding: No. Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b). Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331. Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries. Questioned costs: None. Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award. Cause: Lack of adequate knowledge about subrecipient monitoring requirements. Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight. Repeat Finding: No. Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b). Views of responsible officials: There is no disagreement with the audit finding.
Criteria or specific requirement: Per 2 CFR Part 200.332, pass through entities are responsible for performing monitoring procedures based upon identified risks and must retain documentation to provide reasonable assurance that subrecipients used the subawards for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Pass through entities are also responsible for ensuring and documenting the determination of valid subrecipients per 2 CFR Part 200.331. Condition: There was no documentation to support the key control that the ED reviews and approves subrecipients’ reimbursement requests as a means of monitoring subrecipient activities. Additionally, there was ambiguity in the subaward agreements about whether the grantees were subrecipients, subcontractors, or beneficiaries. Questioned costs: None. Context: In a statistically valid sample, all 13 subrecipients tested were missing evidence of the ED’s review that subrecipient costs and activities were allowable and met the requirements of the award. None of the subaward agreements tested included all of the information required by 2 CFR section 200.332(a) to sufficiently inform the subrecipients that they were recipients of federal funds and must comply with federal statues, regulations ,and terms and conditions of the federal award. Cause: Lack of adequate knowledge about subrecipient monitoring requirements. Effect: Potential for fraudulent transactions and misuse of subaward by subrecipients due to lack of oversight. Repeat Finding: No. Recommendation: CLA recommends adding a review and approval process for all the reimbursement requests and obtaining the support for the payments made in advance for the subawards and review whether subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Additionally, CLA recommends modifying the subaward agreements to include the award information required by CFR 200.332 (b). Views of responsible officials: There is no disagreement with the audit finding.
2023-003 Surveys, Studies, Investigations, Demonstrations, and Training Grants and Cooperative – Assistance Listing No. 66.436; Grant No.84039801, 84039601,94039501; Grant Period – Year ended December 31, 2023. Statement of Condition: Compliance over subrecipient monitoring. Entity did identify the award and applicable requirements, however entity did not evaluate each subrecipient’s risk of noncompliance nor did it monitor subrecipient activities as listed in the contracts “Subaward Performance Reporting” and monitoring procedures per 2 CFR Sections 200.332 (b) and (d) through (f). Criteria: National Association of Wetland Managers’ internal control policies and procedures, and the Uniform Guidance 2 CFR Sections 200.332 (b) and (d)-(f). Cause: Management’s lack of understanding of criteria. Effect: Non-compliance. Questioned Costs: Not identified. Perspective: N/A. Identification: Non-repeat. Recommendation: Management should review above criteria, and implement required procedures. Views of Responsible Officials: NAWM disagrees with the statement of condition and is submitting documentation for NAWM’s activities regarding monitoring procedures per 2 CFR Sections 200.332 (d) through (f) for Assistance Listing No. 66.436; Grant No. 84039801, 84039601, 94039501; Grant Period – Year ended December 31, 2023. Each grant has its own documentation letter addressing each element listed above in its file submitted. A copy of each subawardee’s NICRA is included in their respective files as well as copies of audit findings for each subawardee. Additionally, each subawardee has been awarded federal grants by the U.S EPA and other federal agencies in the past which they have completed successfully. All of these factors, including the information collected on each subaward contract which contain a lot of the required information, and including a search online of the SAM.gov status of each entity, was used to determine any potential risk of noncompliance and no risk was identified by either NAWM or EPA. Auditors’ Evaluation of Views of Responsible Officials: Management’s Response is in conflict with above Statement of Condition, Criteria, and Cause.
FINDING 2023-001 Information on the federal program: Federal Agency: Department of the Treasury Pass-Through Entity: N/A – Direct Grant Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Compliance Requirement: Subrecipient Monitoring Audit Findings: Material Weakness, Noncompliance Criteria: Title 2 Subtitle A Chapter II Part 200 Subparts A and D, Section 200.332, establishes requirements that pass-through entities must adhere to in regard to their subrecipient grant agreements and the monitoring processes of those subrecipients. Condition: The City of Bloomington was unable to identify subrecipients of CSLFRF funding for the purposes of financial reporting and compliance with requirements under 2 CFR 200.332. The City could not distinguish between a subrecipient and a general vendor. Management misreported subrecipient activity on the SEFA, failed to include required contractual language for subrecipient awards in executed agreements, and did not perform monitoring procedures over the subrecipients management identified during audit testing procedures. Cause: The City does not have an effective system of internal controls in place to effectively structure and review CSLFRF subaward agreements or to effectively monitor subrecipients. Effect: Due to lack of required information being present with agreements and the contracts not clearly differentiating between a subrecipient and a beneficiary, there could be noncompliance issues in how funds are spent and recorded by the subrecipient, which could lead to noncompliance issues for the City of Bloomington and its subrecipients. Questioned costs: There are no questioned costs. Context: The 10 subrecipients represent approximately 18%, $1,025,070, of the total award expenditures of $5,590,828, in 2023. The condition reported was prevalent for each subrecipient participating in the award. Identification as a repeat finding, if applicable: Yes, finding 2022-002 in the prior year report. Recommendation: We recommend that the City institute a policy for the handling of subrecipients for all sources of federal funding. The City should review Title 2 Subtitle A Chapter II Part 200 Subpart A and ensure their agreements with subrecipients include all required information. Management should review Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure all necessary monitoring procedures are being performed over subrecipients moving forward. Views of responsible officials and planned corrective actions: Management acknowledges the finding. See management’s corrective action plan attached to this audit report.
Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.332(b). Condition and Context During our audit, we tested a sample of two subrecipients for each assistance listing number in order to determine if the subrecipient agreements contained all required elements per 2 CFR 200.332(b) and ensure sufficient subrecipient monitoring procedures were performed. As a result of our testing, it was identified that the agreements tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. Cause The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, the Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.332. No questioned costs are reported as this requirement is administrative in nature. Recommendation The Organization should address the weakness noted above and update its subrecipient agreements, policies, and procedures to ensure that all required elements are present to comply with the Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Criteria or Specific Requirement OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.332(b). Condition and Context During our audit, we tested a sample of two subrecipients for each assistance listing number in order to determine if the subrecipient agreements contained all required elements per 2 CFR 200.332(b) and ensure sufficient subrecipient monitoring procedures were performed. As a result of our testing, it was identified that the agreements tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. Cause The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements. Effect or Potential Effect Due to the weakness in internal controls and compliance finding noted above, the Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.332. No questioned costs are reported as this requirement is administrative in nature. Recommendation The Organization should address the weakness noted above and update its subrecipient agreements, policies, and procedures to ensure that all required elements are present to comply with the Uniform Guidance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
2023-002 Compliance and Internal Controls over Subrecipient Fiscal Monitoring (Significant Deficiency) (Repeat) U.S. Department of Health and Human Services 93.917 – HIV Care Formula Grants Passed through Texas Department of State Health Services Award Periods: April 1, 2022 to March 31, 2024 Contract No. HHS001022300001 Texas Department of State Health Services HIV Care Formula Grants Award Periods: April 1, 2022 to March 31, 2024 Contract No. HHS001022300001 Texas Department of State Health Services State HIV Service Grants Award Periods: April 1, 2022 to August 31, 2024 Contract No. HHS001022300002 Criteria: Pass-through entities are required to monitor subrecipients in accordance with 2 CFR Section 200.332. Further, under 2 CFR Section 200.303a, non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statutes, regulations, and the terms and conditions of the award. Condition: For the fiscal year ended December 31, 2023, The Resource Group did not timely perform financial monitoring of its subrecipients. Cause: Initially subrecipient monitoring was suspended due to COVID-19 in 2020 and reinstated late 2021. The Resource Group restarted their monitoring of subrecipients, however the monitoring was done by two individuals, one for programming and the other for financial monitoring. Monitoring of programming was completed timely, while the financial monitoring was not. Further, the Finance Director, who was responsible for the financial monitoring, resigned in 2023 and the successor Finance Director was hired in August 2023. After completing training to perform financial monitoring, the Finance Director completed financial monitoring during 2024. Effect: As a result of not completing all financial monitoring and the turnover in Finance Director, The Resource Group is not in compliance with grant requirements. Questioned Costs: None Noted Recommendation: The Resource Group should follow its policies to perform fiscal monitoring on its subrecipients in accordance with 2 CFR Section 200.332. Views of Responsible Officials: See corrective action plan.
2023-002 Subrecipient Monitoring Public Health Training Centers Program – Assistance Listing No. 93.516 Award Number: 1 T29HP46735‐01‐00 – Award Period: September 15, 2022 through September 14, 2025 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health – Assistance Listing No. 93.967 Award Number: G2513_AG-1146 Amendment #1 – Award Period: February 1, 2023 through November 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition: During our testing of subrecipients, we noted documentation was not maintained demonstrating the Organization checked for suspension and debarment prior to contracting with subrecipients, subrecipient vs contractor determinations, evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring, or obtaining/reviewing the most recent single audit reports for subrecipients to address findings related to a particular subaward. Criteria: According to 2 CFR 200.331, pass-through entities must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. 2 CFR 200.332 requires every subaward agreement include certain information including the subrecipient’s unique entity identifier (see paragraph (a) for a list of all required data elements); additionally, all pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in § 200.425. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations. 2 CFR 180.22 requires that contract awards not be made to parties listed on the government wide exclusions in the system for Award Management, which contains the names of parties debarred, suspended or otherwise excluded by agencies as well as parties declared ineligible under statutory or regulatory authority. Questioned Costs: None. Cause: The Organization did not have a process in place to ensure all required elements of subrecipient monitoring were documented and retained in their records. Effect: Inadequate monitoring procedures and records may not detect subrecipient noncompliance on a timely basis. This could result in the Organization entering into subrecipient agreements with organizations who are ineligible to receive federal funds or might otherwise not comply with federal laws and regulations. Recommendation: We recommend that management implement procedures to ensure that future subrecipient agreements are compared against all requirements in 2 CFR 200.331, 2 CFR 200.332, and 2 CFR 180.22 and that formal documentation of such considerations be maintained. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separately issued Corrective Action Plan.
Subrecipient Monitoring Federal Department – U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing #93.391 County Department – Department of Public Health Finding 2023 – 005 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D—Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that “All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F— Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.” CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not adequately comply with its subrecipient monitoring requirements in accordance with federal regulations. CAUSE Based on discussions with management, the cause of this finding was due to DPH/CCH identifying a consultant agency to conduct the subrecipient monitoring; this was accomplished October 2023. Current Status: These documents were created, shared with the auditor pending management approval; 1) Subrecipient Monitoring Policy 2). Subrecipient Commitment Form 3). Subrecipient Determination Tool 4). Subrecipient Risk Assessment and Monitoring Guide. EFFECT Failure to adequately monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and DPH’s inability to adequately perform risk assessments on its subrecipient(s). QUESTIONED COSTS None. CONTEXT During the prior audit period, we noted 6 instances (of 27 subrecipients), whereby adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Also, we noted no evidence of the performance of subrecipients’ risk assessment and whether the subrecipients were required to have a Single audit conducted. This resulted in the 2022 audit finding and subsequent corrective action planned prepared by DPH to address the finding, which was anticipated to be completed by December 31, 2023. During the current audit period, we received DPH’s current year status of the prior audit finding, noting that risk assessment and monitoring will be ongoing during the 2023 Single audit. To assess the current year’s status, we reviewed 5 of 35 subrecipients, noting that risk assessments were conducted in April 2024. We also noted that 4 of the 5 subrecipients reviewed were subject to a Single Audit per the risk assessment documentation. However, we noted no evidence financial monitoring conducted, including whether a Single Audit report was obtained and reviewed by DPH. IDENTIFICATION OF REPEATED FINDINGS Repeated (Prior Finding No. 2022-009) RECOMMENDATION We recommend DPH implement its prior corrective action plan for any future subrecipients awarded under the federal program. Also, procedures should be in place to adequately document financial monitoring conducted, as well as the review of the Single Audit report, as required by federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 56.
Subrecipient Monitoring Federal Department – U.S. Department of Health and Human Services Federal Award Identification Number and Year: NU58DP006993 and 2022/2023 COVID-19 - Community Health Workers for Public Health Response and Resilient, Federal Assistance Listing #93.495 County Department – Department of Public Health Finding 2023 – 006 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D—Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that “All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F— Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.” CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not perform adequate monitoring of its subrecipients as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding was due to DPH/CCH identifying a consultant agency to conduct the subrecipient monitoring; this was accomplished October 2023. Current Status: These documents were created, shared with the auditor pending management approval; 1) Subrecipient Monitoring Policy 2). Subrecipient Commitment Form 3). Subrecipient Determination Tool 4). Subrecipient Risk Assessment and Monitoring Guide. EFFECT Failure to adequately monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and DPH’s inability to adequately perform risk assessments on its subrecipient(s). QUESTIONED COSTS None. CONTEXT During the current audit period, we noted 12 subrecipients were awarded funds. During our review of three (3) subrecipients, we noted the following: For all three subrecipients, we noted that adequate documentation was not maintained to support the financial monitoring of these subrecipients. Also, no documentation was provided to verify whether the subrecipients were required to have a Single Audit conducted, including DPH’s review of the report, and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). For one subrecipient, we noted documentation was not maintained to support DPH’s evaluation of the subrecipient’s risk of noncompliance and the frequency of monitoring to be conducted by DPH based on the assessed risk. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH implement procedures to ensure that adequate documentation is maintained to support financial monitoring conducted, evaluation of each subrecipient’s risk of noncompliance and review of the Single Audit report, as required by federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 56.
Subrecipient Monitoring Federal Department – U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing #93.391 County Department – Department of Public Health Finding 2023 – 005 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D—Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that “All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F— Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.” CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not adequately comply with its subrecipient monitoring requirements in accordance with federal regulations. CAUSE Based on discussions with management, the cause of this finding was due to DPH/CCH identifying a consultant agency to conduct the subrecipient monitoring; this was accomplished October 2023. Current Status: These documents were created, shared with the auditor pending management approval; 1) Subrecipient Monitoring Policy 2). Subrecipient Commitment Form 3). Subrecipient Determination Tool 4). Subrecipient Risk Assessment and Monitoring Guide. EFFECT Failure to adequately monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and DPH’s inability to adequately perform risk assessments on its subrecipient(s). QUESTIONED COSTS None. CONTEXT During the prior audit period, we noted 6 instances (of 27 subrecipients), whereby adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Also, we noted no evidence of the performance of subrecipients’ risk assessment and whether the subrecipients were required to have a Single audit conducted. This resulted in the 2022 audit finding and subsequent corrective action planned prepared by DPH to address the finding, which was anticipated to be completed by December 31, 2023. During the current audit period, we received DPH’s current year status of the prior audit finding, noting that risk assessment and monitoring will be ongoing during the 2023 Single audit. To assess the current year’s status, we reviewed 5 of 35 subrecipients, noting that risk assessments were conducted in April 2024. We also noted that 4 of the 5 subrecipients reviewed were subject to a Single Audit per the risk assessment documentation. However, we noted no evidence financial monitoring conducted, including whether a Single Audit report was obtained and reviewed by DPH. IDENTIFICATION OF REPEATED FINDINGS Repeated (Prior Finding No. 2022-009) RECOMMENDATION We recommend DPH implement its prior corrective action plan for any future subrecipients awarded under the federal program. Also, procedures should be in place to adequately document financial monitoring conducted, as well as the review of the Single Audit report, as required by federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 56.
Subrecipient Monitoring Federal Department – U.S. Department of Health and Human Services Federal Award Identification Number and Year: NU58DP006993 and 2022/2023 COVID-19 - Community Health Workers for Public Health Response and Resilient, Federal Assistance Listing #93.495 County Department – Department of Public Health Finding 2023 – 006 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D—Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that “All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F— Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.” CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not perform adequate monitoring of its subrecipients as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding was due to DPH/CCH identifying a consultant agency to conduct the subrecipient monitoring; this was accomplished October 2023. Current Status: These documents were created, shared with the auditor pending management approval; 1) Subrecipient Monitoring Policy 2). Subrecipient Commitment Form 3). Subrecipient Determination Tool 4). Subrecipient Risk Assessment and Monitoring Guide. EFFECT Failure to adequately monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and DPH’s inability to adequately perform risk assessments on its subrecipient(s). QUESTIONED COSTS None. CONTEXT During the current audit period, we noted 12 subrecipients were awarded funds. During our review of three (3) subrecipients, we noted the following: For all three subrecipients, we noted that adequate documentation was not maintained to support the financial monitoring of these subrecipients. Also, no documentation was provided to verify whether the subrecipients were required to have a Single Audit conducted, including DPH’s review of the report, and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). For one subrecipient, we noted documentation was not maintained to support DPH’s evaluation of the subrecipient’s risk of noncompliance and the frequency of monitoring to be conducted by DPH based on the assessed risk. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH implement procedures to ensure that adequate documentation is maintained to support financial monitoring conducted, evaluation of each subrecipient’s risk of noncompliance and review of the Single Audit report, as required by federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on page 56.
Finding 2023-001 – Significant Deficiency in Internal Control - Subrecipient Monitoring Federal Program: Block Grants for Community Mental Health Services Assistance Listing Number: 93.958 Federal Agency: U.S. Dept of Health and Human Services Passed-Through Agency: Colorado Department of Health Services Behavioral Health Division Award Number: 23 IBEH 175467 / 24 IBEH 184610 / 24 IBEH 187913 Award Year: 2023 and 2024 Compliance Requirement: Subrecipient Monitoring Questioned Costs: Not determinable Criteria: 2 CFR 200.332(a) requires that every subaward agreement includes certain information, including 1) subrecipient's unique entity identifier; 2) name of federal awarding agency; 3) assistance listing number and title; 4) identification of whether the award is R&D; and 5) indirect cost rate for the federal award (including if the de minimis rate is charged). 2 CFR 200.332(b) requires an evaluation of the subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of subawards as part of subrecipient monitoring and identifies specific considerations to be made during this process. 2 CFR 180.22 requires that contract awards not be made to parties listed on the government wide exclusions in the System for Award Management, which contains the names of parties debarred, suspended or otherwise excluded by agencies as well as parties declared ineligible under statutory or regulatory authority. Condition and Context: Subrecipient agreements entered into did not contain all required components as stipulated in 2 CFR 200.332(a). While the organization did have policies and procedures to evaluate its subrecipients, not all considerations noted in 2 CFR 200.332(b) are included in the policies. Furthermore, formal documentation was not maintained of specific considerations to the subrecipients that the Organization ultimately contracted with. Formal documentation was also not maintained related to verification that the subrecipients were not on the government wide exclusions list. Effect: Subrecipient agreements are missing certain data points that are required by the federal government. This could impact the subrecipients in their reporting. Lack of proper subrecipient monitoring, including the risk assessment component and verification of suspension/debarred status could result in the Organization entering into subrecipient agreements with organizations that will not comply with federal laws and regulations. Cause: The omitted components of the agreements, including lack of formal documentation of the risk assessment and verification that subrecipients were not on the federal governmentwide exclusions list were not detected by the Organization’s internal control process. Recommendation: We recommend that management implement procedures to ensure that future subrecipient agreements are compared against all requirements in 2 CFR 200.332(a), 2 CFR 200.332(b) and 2 CFR 180.22 and that formal documentation of such considerations be maintained. Planned Corrective Actions and View of Responsible Officials: Management agrees with the finding and is in the process of updating policies and procedures to be in compliance with the requirements of 2 CFR 200.332(a), 2 CFR 200.332(b) and 2 CFR 180.22.
Finding 2023-001 – Significant Deficiency in Internal Control - Subrecipient Monitoring Federal Program: Block Grants for Community Mental Health Services Assistance Listing Number: 93.958 Federal Agency: U.S. Dept of Health and Human Services Passed-Through Agency: Colorado Department of Health Services Behavioral Health Division Award Number: 23 IBEH 175467 / 24 IBEH 184610 / 24 IBEH 187913 Award Year: 2023 and 2024 Compliance Requirement: Subrecipient Monitoring Questioned Costs: Not determinable Criteria: 2 CFR 200.332(a) requires that every subaward agreement includes certain information, including 1) subrecipient's unique entity identifier; 2) name of federal awarding agency; 3) assistance listing number and title; 4) identification of whether the award is R&D; and 5) indirect cost rate for the federal award (including if the de minimis rate is charged). 2 CFR 200.332(b) requires an evaluation of the subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of subawards as part of subrecipient monitoring and identifies specific considerations to be made during this process. 2 CFR 180.22 requires that contract awards not be made to parties listed on the government wide exclusions in the System for Award Management, which contains the names of parties debarred, suspended or otherwise excluded by agencies as well as parties declared ineligible under statutory or regulatory authority. Condition and Context: Subrecipient agreements entered into did not contain all required components as stipulated in 2 CFR 200.332(a). While the organization did have policies and procedures to evaluate its subrecipients, not all considerations noted in 2 CFR 200.332(b) are included in the policies. Furthermore, formal documentation was not maintained of specific considerations to the subrecipients that the Organization ultimately contracted with. Formal documentation was also not maintained related to verification that the subrecipients were not on the government wide exclusions list. Effect: Subrecipient agreements are missing certain data points that are required by the federal government. This could impact the subrecipients in their reporting. Lack of proper subrecipient monitoring, including the risk assessment component and verification of suspension/debarred status could result in the Organization entering into subrecipient agreements with organizations that will not comply with federal laws and regulations. Cause: The omitted components of the agreements, including lack of formal documentation of the risk assessment and verification that subrecipients were not on the federal governmentwide exclusions list were not detected by the Organization’s internal control process. Recommendation: We recommend that management implement procedures to ensure that future subrecipient agreements are compared against all requirements in 2 CFR 200.332(a), 2 CFR 200.332(b) and 2 CFR 180.22 and that formal documentation of such considerations be maintained. Planned Corrective Actions and View of Responsible Officials: Management agrees with the finding and is in the process of updating policies and procedures to be in compliance with the requirements of 2 CFR 200.332(a), 2 CFR 200.332(b) and 2 CFR 180.22.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 - ARPA Prevention ALN 93.959 – SAPT Block Grant - Prevention ALN 93.959 – COVID-19 - Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 - ARPA Prevention ALN 93.959 – SAPT Block Grant - Prevention ALN 93.959 – COVID-19 - Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2023-001 – Communications with Subrecipients (repeat comment) Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.959 – COVID-19 - ARPA Prevention ALN 93.959 – SAPT Block Grant - Prevention ALN 93.959 – COVID-19 - Prevention Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the PIHP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.